Enel Brasil's Commitment to Transparency and Integrity
Enel Brasil considers transparency and integrity to be essential to its business. For this reason, it has standards and a code of conduct applicable to all its employees and the supplier chain, which express the ethical commitments and responsibilities in carrying out business activities and operations developed by the employees.
Enel’s values are based on integrity, as outlined in the Code of Ethics, the Human Rights Policy (based on the United Nations Universal Declaration of Human Rights), the Zero Tolerance to Corruption Plan (Zero Tolerance Plan), the Enel Group’s Global Compliance Program, the Criminal Risk Prevention Model, as well as local regulations that guide the implementation of Integrity Programs across Enel companies worldwide. In Brazil, this includes the Anti-Corruption Law - Law No. 12,846/2013.
Program Structure
The Enel Global Compliance Program reinforces the company’s commitment to the highest ethical, legal, and professional standards to improve and preserve the Group's reputation. It establishes general conduct standards that complement internal policies and procedures. Additionally, Enel Brasil follows Brazilian Law No. 12,846/2013 (the Anti-Corruption Law).
As an integral part of the Integrity Program, the Criminal Risk Prevention Model (MPRP) consists of an interconnected control framework designed to prevent criminal activities within the company's operations, mitigate risks related to the criminal liability of the legal entity and individuals acting on its behalf, and ensure compliance with Law 12,846/13. The model also helps strengthen governance structures and values, aligning with the best local and international practices.
The program outlines the expected behaviors and general principles of action for Enel Group employees in Brazil, which are rooted in the company’s core values to achieve business objectives while preventing risk materialization. It applies to all employees in roles related to representation, management, operations, or oversight of the company, as well as those acting on behalf of the company. The company also requires all affiliates, suppliers, and partners to adopt behaviors consistent with the established ethical principles.
Compliance
At Enel, our Compliance department, together with Internal Audit, is structured to ensure independent, impartial, and autonomous operation. In addition to ensuring that processes comply with standards, Internal Audit also strives to operate strategically, aligning with the goals of different areas. Internal Audit is dedicated to assessing compliance with regulations and procedures, considering factors such as fraud and corruption. It operates through an annual audit program, independently coordinated from the Executive Board.
To manage the overall Integrity Program, the Board of Directors appoints a Responsible Officer for Crime Prevention, who, supported by the Internal Audit team, also works closely with other areas of the organization.
Control Tools
In order to ensure the control of actions identified as unethical, Enel Brasil has various tools for evaluating and properly addressing these issues.
Ethical Channel:
Through the Ethical Channel, anyone can report practices and behaviors that violate the principles of the Code of Ethics.
Reports are received by an external company, ensuring complete impartiality in handling the cases. All communications will be treated with confidentiality, ensuring no retaliation and anonymity for whistleblowers.
The management, investigation, and resolution of reports received through the Ethical Channel are the responsibility of the Internal Audit department. All claims are investigated, and if any non-compliance with company policies or requirements is identified, appropriate measures are taken.
Criminal Risk Prevention Model:
One of the main ways to monitor the Integrity Program is by reviewing the control activities defined in the Criminal Risk Prevention Model.
The control activities subject to review are defined based on various criteria, such as critical controls, new controls, controls not tested in the last reviews, and controls that showed recommendations for improvement in previous reviews.
Continuous Audits:
Continuous audits are also necessary for the effective maintenance of the Integrity Program, as periodic reviews of processes deemed most sensitive to the group can help improve the program continuously, as well as identify new risks and/or the need for adjustments in certain control activities.
Training:
To promote a culture of transparency and integrity for all employees and partners of the group, communication and training plans are defined annually. These plans are based on various factors, such as recurring issues in reports received through the whistleblower channel, issuance and review of internal policies, and other sensitive topics requiring ongoing attention.
The activities outlined in the plan are carried out through communication campaigns, awareness weeks, learning tracks, and in-person or virtual seminars and workshops.
Due Diligence:
To ensure comprehensive mitigation of corruption risks arising from third-party relationships, Enel conducts pre-assessment of commercial agreements made by the group. The Integrity Program and Enel’s Regulatory System include various complementary norms that form a robust control system to verify the integrity of suppliers, clients, counterparties involved in sponsorships and donations, as well as partners in joint ventures.
Ethical Documents:
Enel has a strong regulatory system that includes, in addition to our Code of Conduct, several policies and procedures aligned with the best business practices, as well as with the Group’s Global Compliance Program and local legislation.
*Documents available only in portuguese